Enclosure 1

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EPA Information Collection Request for Nitric Acid NSPS (Subpart G)

Plant Data

Facility name JR Simplot Company Helm Plant

Facility owner (ultimate parent owner) JR Simplot Company 

Plant Location - Address 12688 South Colorado Avenue

Latitude/Longitude for Plant 36.54944/-120.112222

Describe location of latitude/longitude Center of Facility

City, State, ZIP code Helm, CA 93627

Year plant began operation October 1980

Information for Each Nitric Acid Production Line

(change names as needed and use the same names in the Excel spreadsheet)

Line 1 Line 2 Line 3

Year line began operation October 1980

Production Rate (Tons/Day of 

100% Acid) 231 tons per day

Production Rate Range (Tons/Day of 

100% Acid) 190-280

Subject to Subpart G? yes

Process Type (high/low pressure) low

Oxidation pressure (psia) 100-110 lbs

Absorption pressure (psia) Design = 120 psia

Operation = 105 psia

% Acid strength Typically Produced 57%

Operating Hours/Year Line 1 Line 2 Line 3

2008 8400

2007 7546

2006 7823

Control Technology 

(list as many as applicable)

NSCR

% Control Efficiency (based on most 

recent compliance test)

Line 1 Line 2 Line 3

NOX >99%

NO not available

NO2 not available
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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Permit Limits for Each Nitric Acid Production Line

(Fill in all applicable rows)

Line 1 Line 2 Line 3

NOX Emissions (tpy) n/a

 NOX Emissions (lb/hr) 180 ppm 3 hr average

NOX Emissions (lb/ton of 100% 

acid) n/a

Permitted NOX control efficiency, if 

applicable n/a

If your permit includes limits for 

other pollutants, please include as 

much detail as possible below:

Line 1 Line 2 Line 3

particulate matter emissions Not > 0.1 Grains/scf

Sulfur

not > .02% by

volume, 2000 ppmv, 

on dry basis averaged 

over 15 consecutive 

minutes 

Gases discharged not > 10% opacity

Visible emissions Based on 10% opacity
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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For each control device, please provide the key design parameters 

Extended Absorption (Nitric Acid Production Line Name)

Length Approximately 65'

Design Information 

(gal/ 10 3acfm, etc) 50-60 gpm Nitric Acid produced

3750-3900 scf bleach air

Operation and Maintenance required 

(Last 10 years) Tube Cleaning, leak repair, hose replacement.

Year absorption capacity was added n/a

If you use an additive in your absorption column:

Name of additive (i.e., hydrogen 

peroxide) n/a

Concentration of additive (%): n/a

Explain the process:

Addition rate (gallons per hour): n/a

Ratio of additive to water: n/a
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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SCR (Nitric Acid Production Line Name)

Type of Catalyst N/A use of NSCR

Is Catalyst New or Regenerated?

Catalyst Life (Design/Actual)

Catalyst Volume (m3)

Flow rate (scfm)

Ammonia injection rate (lb/hr)

Operation and Maintenance required 

(Last 10 years)

Year began operation
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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For each control device, please provide the key design parameters

NSCR (Nitric Acid Production Line Name)

Reductant used (methane, H2, etc) Butane

Rate of reductant used 75-85 scfm butane

Type of catalyst The catlyst in operation is multi component precious metal catalyst. 

Precous metals used are Pd, Pt and Rh

Catalyst Volume (m3) 35 ft 3

Flow rate (scfm) 22,000

Is Catalyst New or Regenerated? new

Catalyst Life (Design/Actual) guarantee is for one year. Anticpated life is 4-6 years.

Operation and Maintenance required 

(Last 10 years) Spent catlyst replacement

Year began operation 1980
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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Cost Information by Control Technology

Production Line

Pollutant 

Controlled

Control 

Technology

Capital

(Yr of Cost basis)

Annual O & M

(Yr of cost basis)

Nitric Acid NOx NSCR $450,000 

(Replacement 

estimates 2010)

$1,025,000 (Budget 

2010)

Please provide additional cost information, comments, or notes below:

Replacement costs, at today metals prices for the Abatement catalyst would be $221,117.00, with 6-8 

week delievery.

Replacement costs of Catalyst, butane used/year, mainteance = 24 hour remove and install basket, 8 hr 

replace catalyst

The cost of butane has rapidly increased over the past year and accounts for the majority of our O&M 

budget for this equipment
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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Continuous Emission Monitoring Systems

CEMS Information

Plant CEMS data recorded 

concurrent with test runs (i.e., 

concentration, etc.). NOx concentration

CEMS Manufacturer Rosemont Analytical

CEMS Model Number Model 951 A

Description of sample extraction and 

conditioning or dew point 

maintenance systems

Sample is drawn from stack through a heated probe 

assembly. Basic parts of this assembly are probe, 

ceramic filter and heater. 

Sample travels from probe through heated sample 

line to inlet of primary exchanger of chiller. 

Sample travels from discharge of primary exchanger 

through vacuum gauge to suction side of vacuum 

pump.

Sample is pushed out of discharge side of vacuum 

pump, through pressure gauge, to inlet side of 

secondary exchanger of chiller. 

Sample continues from discharge of secondary 

exchanger to inlet of Zeks coalescing filters, 2each, 

and from discharge of filters to inlet of NH3 

scrubbers, 2each. 

Ability to distinguish between NO 

and NO2? No

Identify all periods of startup, 

shutdown, and malfunction, 

regardless of whether the event 

caused an exceedence (during the 

past 3 years)

DATE time interval

2/7/2006 18 Hrs 20 mins

4/11/2006 25 Hrs 20 mins

5/18/2006 9 Hrs 30 mins
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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6/8/2006 22 Hrs

6/10/2006 9 Hrs 30 mins

6/25/2006 6 Hrs 30 mins

6/25/2006 83 Hrs

7/23/2006 27 Hrs

8/14/2006 43 Hrs

10/16/06 thru 11/11/06 27Days & 2 hrs

01/13/07 thru 01/17/2007 3 Days & 16 Hrs

3/20/2007 25 Hrs

04/21/07 thru 04/22/2007 15 Hrs

05/14/07 thru 05/15/2007 23 Hrs

06/08/07 thru 06/09/2007 13 Hrs

06/23/07 thru 06/24/2007 21 Hrs

06/24/07 thru 06/25/2007 7 Hrs

7/5/2007 6 Hrs

07/13/07 thru 07/14/2007 24 Hrs

09/25/07 thru 09/27/2007 13 Hrs

06/23/07 thru 06/24/2007 58 Hrs

09/28/07 thru 09/30/2007 96 Hrs

10/01/2007 THRU 10/28/2007 28 Days

11/10/2007 18 Hrs

11/11/2007 THRU 11/15/2007 4 Days

11/16/2007 20 Hrs

01/28/08 thru 01/30/08 43 Hrs

2/5/2008 12 Hrs

04/07/08 thru 04/09/08 46.4 Hrs

04/13/08 thru 04/14/08 14..2 Hrs

05/03/08 thru 05/05/08 43.1 Hrs

6/17/2008 22.4 Hrs

8/20/2008 6 Hrs

08/26/08 thru 08/27/08 25 Hrs

10/26/08 thru 10/27/08 35 Hrs
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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11/11/08 thru 11/13/08 69 Hrs

11/24/08 thru 11/25/08 29 Hrs

12/18/08 thru 12/20/08 57 Hrs

2/14/2009 4 hours 30 mins

3/10/2009 9 hrs 

3/23/2009 4 hrs 12 mins

2/9/2009 thru 2/12/2009 36 hrs

3/10/2009 thru 3/11/2009 4 hrs 10 mins

3/23/2009 thru 3/24/2009 3 hrs 18 mins

4/20/2009 thru 4/23/2009 72 hrs

2/14/2009 62 hrs 35 mins

3/10/2009 18 hrs 53 mins

7/10/2009 thru 7/13/2009 62 hrs 35 mins

7/13/2009 thru 7/15/2009 18 hrs 53 mins

10/09/2009 thru 10/20/09 24 hrs

10/23/2009 3 hrs 

10/23/2009 5 hrs

10/23/2009 1 hr 15 mins

10/25/2009 21 hrs 25 mins

10/26/2009 thru 10/27/2009 23 hrs 42 mins

10/28/2009 13 min

1/11/2010 thru 1/14/2010 35 hrs 49 min

1/13/2010 5 hrs 49 mins.

2/22/2010 10 hrs 36 mins.

Capital costs $49,894 equipment

Operation and Maintenance costs

Operations costs per year = $11,700 Maintenance costs (man hrs) = 

$1,567

Cost of quarterly audits Annual tests $10,950

Year began operation 1980

CEMS Data (Monthly and Annual)

Include monthly and annual NOX CEMS data for the last 3 years. Please submit the CEMS 

data electronically. (SEE ATTACHED DATA)
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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General Discussion

1. Please provide your thoughts on trends in nitric acid production as far as type of process that 

is used; types of absorber used, trends in selecting control devices, improvements in control 

efficiency in existing control devices, energy efficiency. 

We have not identified a more cost-effective way to reduce our emissions, but continue to 

investigate new technologies and evaluate the cost-benefits of each.

2. Please describe your thoughts on the air pollution controls that are used at your facility such 

as reliability, O&M costs including energy penalty, etc. 

The largest cost of our current control method is the required Butane. The cost off Butane has 

increased sharply in the last year and is the primary cost associated with operating the NSCR.

3. Please provide recommendations on the revisions you would like to see in this NSPS. 

40 CFR 60.73 specifies a span value of 500 ppm for the Continuous NOx Emission Monitor. At this 

value, the span value is very high compared to the normal operating range of about 10-20 ppm. During 

an upset situation, 500 ppm is very low compared to spikes in the range of 3000 ppm. A variable span 

range would ensure accuracy of the instrument over the range the instrument measures.

40 CFR 60 Appendix B is applicable for sources using stack tests as the method of demonstrating 

compliance. 40 CFR 60 Appendix F applies at sources where Continuous Emission Monitors are used to 

demonstrate compliance. This needs to be clearly stated in the regulations as we have seen agencies 

misinterpret the applicability of Appendix F. We have seen instances where EPA has provided written 

clarification and guidance, but it needs to be reflected in actual rule as well.

It is not possible to comply with existing emission and opacity limits during periods of startup, shutdown, 

and malfunction. Therefore, it is important to clarify within Subpart G that the emission standards do not 

apply during these periods. An alternate approach would be to create a separate considerably higher 

emission limit for these periods. 
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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Startup, Shutdown, and Malfunction

1. Please describe the maximum emission levels of NOX or NH3 expected during a startup, 

shutdown, and malfunction event. 

The maximum emissions levels of NOx during statup, shutdown, and malfunction events are 

greater than 2,500 ppm. Actual ppm is higher than what we are capable of measuring at this 

time.

2. Please describe how long excess/elevated emissions NOX or NH3 will typically occur during 

a startup, shutdown, and malfunction event. 

The excess/elevated emissions of NOx could be less than 10 minutes to 1/2 hour during 

shutdown, startup, and any malfunction events.

3. Please describe any equipment or work practices that are employed to minimize or eliminate 

the quantity or duration of excess/elevated emissions of NOX or NH3 during startup, 

shutdown, and malfunction events.

During start-up, we preheat the catalyst in the NSCR to reduce emissions. During all 

evolutions, emissions are monitored closely to ensure prompt corrective action, 

including shut-down. During normal shutdown, the system is purged through the 

absorber to prevent excess emissions. During a malfunction-shutdown, there are no 

controls, beyond the shutdown itself, to reduce emissions.
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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Emission Testing 

Note: Previous emission testing performed does not meet the prescribed methods below. 

Testing is scheduled for April 7 and 8, 2010. 

1. Include emissions testing conducted during the last five years. Include tests for NOX, and 

NH3. Read and follow the guidance below.

2. Test method data of interest include those performed according to EPA Methods 7, 7A, 7B, 

7C, 7D, or Method 320.

3. Method 7E (for NOX) data can be submitted, but only if the testing was performed with the 

following modifications for nitric acid plants. Because of the propensity of NO2 to be 

absorbed by water, the sampled gas must not contact any condensate, and the efficiency of 

any NO2 to NO converter (if needed by the detection principle of the instrument) must be 

determined and documented as described in the method. For wet basis measurement systems, 

the tester must measure and report temperature data to show that the sample line and all 

sample transport components up to the inlet of the analyzer (and, for hot-wet extractive 

systems, also the analyzer) were maintained above the stack gas dew point. Use of a dilution 

probe to reduce the dew point is an acceptable procedure, if documented. Section 8 of 

Method 7E describes the measurement system performance tests and documentation required 

by the method, both prior to and following sampling. NO2 calibration gas must be substituted 

for NO calibration gas in the performance of system bias checks. The alternative mentioned 

in Section 8.6 to follow the dynamic spike procedure in Section 16.1 is acceptable, but only 

with NO2 spike gas. The dynamic spiking procedure is strongly recommended.

4. If you do not have emission test data for NOX using a method in note 2 or using Method 7E

according to the modified protocol in note 3, you must conduct a stack test to determine 

NOX emissions following one of the approved methods above.

5. If you do not have emission test data for NH3, you must conduct a stack test to determine 

the emissions using the procedures of Method 320.

6. If a concentration is at or below the applicable method’s detection level, then provide 

information about the method (title and source), the calculated detection level in units of the 

applicable raw material or emissions concentration or mass rate, and the procedure for 

determining the detection level.

7. Additional stack testing guidance is contained in Enclosure 7.